July 9, 2002

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn:    Division of Investment Management

         Re:      Withdrawal of 485B Filing
                  Accession No. 0000067813-97-000010
                  ----------------------------------

Dear Sir or Madam:

     Please  withdraw  the above noted 485B filing that was filed in 1997.  This
document should have had an NSAR-B subhead and not a 485B subhead.  Looking back
at our records, it was later filed correctly.

     Please  contact  me at  (617)  295-2578  with  any  questions  you may have
concerning the foregoing.


                                                    Very truly yours,



                                                    /s/Linda DiSola
                                                    -----------------------
                                                    Linda DiSola
                                                    Manager - Edgar Group